1.Entities that place securities in the market do not qualify as withholding agents in Italy The Italian Supreme Court, with the decision no. 22419 of 4 August 2025, stated that, with respect to withholding taxes on interest and capital income referred to in Art. 26(3) of the Presidential Decree 600/73, … Read more
1.Sales of real estate companies shares are relevant in Italy With their ruling no. 175 of 4 July 2025, the Italian Tax Authorities have clarified that the capital gain derived by a US opaque trust from the sale of shareholdings in a Swiss company whose assets are represented solely by … Read more
1.Game bonuses are not relevant for Italian digital tax purposes With the statement of practice no. 6 of 3 June 2025, the Italian Tax Authorities have clarified that, in online games, gaming bonuses are not relevant to determine taxable base for digital services tax purposes (so-called “web tax”, governed by … Read more
1.Black listed countries with reference to dividends and capital gains The ruling reply no. 131 of 13 May 2025 provided clarifications on the identification of the “preferential” nature of foreign dividends (which precludes the exemption of 95% of such income). If the foreign company distributing the dividends is not controlled … Read more
1.Participation exemption regime potential in breach of EU freedoms On the 10 April 2025, the Chartered Accountants Italian Association has issued its document no. 229 which analyses the new participation exemption regime introduced in Italy with respect to capital gains derived by companies resident in the EU or EEA on … Read more
1.Italian Tax Authorities clarify the boundaries of the in-bound workers regime The ruling replies no. 71 and 74 of 12 March 2025 provide some clarifications on the concept of “high qualification or specialization” referred to into Art. 5(1)d) of the Legislative Decree 209/2023 in connection to the in-bound workers regime. … Read more
1.The longer time threshold also applies for self-employed benefitting from the in-bound workers Pursuant to ruling no. 22 of 7 February 2025, in order to benefit from the in-bound workers regime, the requirement of having spent six or seven years abroad (instead of the ordinary three pursuant to Article 5(1) … Read more